Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Camping, rafting, and backpacking throughout the West has been part of my entire life. I rely on these places for solitude and the chance to connect with nature, and the proposed rescission of the 2001 Roadless Area Conservation Rule threatens both. I oppose it. The agency's own record undermines the wildfire rationale at the center of this proposal. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the same document being used to justify opening these areas. The agency must explain how it can cite wildfire management as a reason for rescission while its own analysis documents that road access drives ignition rates upward. I ask that the agency explain why this proposal departs from those prior findings and how it reconciles the rescission with its own conclusions about ignition risk. The ignition data makes the contradiction more precise, not less. The DEIS reports that "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." A ratio that wide is not a rounding error. The places I have spent my life traveling through, camping and backpacking in the backcountry of the West, are precisely the kind of low-ignition environments this data describes. The agency has not explained how new road access into these areas would produce a net improvement in fire conditions. It must quantify the expected increase in human-caused ignitions from new road access and weigh that number honestly against any claimed reduction in wildfire hazard. Access to clean water should be a basic human right. Adding roadways to America's already over-taxed watersheds will do irreparable harm, and the agency's own analysis does not contradict that concern. The DEIS acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The watersheds fed by these roadless areas supply drinking water to millions of people. Opening them to road construction is not a reversible experiment. The agency should explain what safeguards, if any, it has analyzed that would prevent the kind of sediment loading its own documents describe, and it should respond to the water quality implications of this rescission. The regulatory flexibility certification in this rulemaking does not hold up. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The no-impact conclusion is reached by spreading projected losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. Some of those firms may lose these receipts entirely. Spreading the damage thinly across a national average does not make it disappear for the businesses actually exposed. The agency should withdraw the certification and assess the impact on the specific small entities operating inside the potentially affected roadless areas. Finally, the agency has not fulfilled its own invitation. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. I have organized my outdoor life around the existence of these protected areas. Under established administrative law, an agency reversing a longstanding policy must assess the reliance interests its prior rule created, not merely ask for them and then set them aside. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Kate Lips Salt Lake City, UT

To the USDA Roadless Rule Team: As a Coloradan, and a wildlife enthusiast, I believe the 2001 rule is the single most important land management instrument and the threat of its removal is not only catastrophic but infuriating. Every year, I take a fall trip to explore these beautiful mountains and every year I am left with wonder. Seeing new wildlife, a new sunset, a new plant, a riverbed - it never ceases to amaze me. The protection of these ecosystems are imperative for us, but also for all. Being able to backpack through these undisturbed mountains and connect with other life is one of the few things that bring me joy and peace in such a hectic world. Roads end that possibility. Regarding the Mount Antero in the Pike & San Isabel NFs- Alpine and Subalpine Climate Refugia Connectivity — The area spans from 13,600 feet to 14,276 feet across multiple subalpine and alpine ecosystem types—Rocky Mountain subalpine spruce-fir forest, alpine tundra, and bristlecone pine woodland—creating an intact elevational gradient that allows species to shift their ranges as climate conditions change. This vertical connectivity is critical as warming temperatures push suitable habitat upslope; species dependent on cool conditions can only persist if they can move continuously to higher elevations without fragmentation. Road construction fragments this gradient by creating edge effects, altering microclimate through canopy removal, and introducing invasive species along disturbed corridors, which would trap populations in lower-elevation refugia that are becoming increasingly unsuitable. DEIS Narrative Exceeds the 150-Page Statutory Limit With No Extraordinary-Complexity Determination on the Record The Draft EIS exceeds the statutory page limit and contains no determination authorizing it to do so. Volume I of the Draft EIS is 333 pages. Its narrative text runs from the Introduction at page 9 through page 248. References Cited occupies pages 249 through 285, and the List of Appendices and Appendices 1 through 5 occupy pages 286 through 333. Excluding citations and appendices, as the statute directs, the environmental impact statement is therefore approximately 240 pages long. The applicable limit is 150 pages. 42 U.S.C. 4336a, enacted by the Fiscal Responsibility Act of 2023, limits an environmental impact statement to 150 pages excluding citations and appendices, and permits 300 pages only where the proposed agency action is of extraordinary complexity. USDA's NEPA procedures implement the same limits at 7 CFR 1b.7(a) and (i). The Draft EIS expressly adopts those procedures, stating at page 9 that the Forest Service "has prepared this draft environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations," and that "all references to 7 CFR 1b within this document refer to the interim rule." The document therefore exceeds the 150-page limit by approximately 90 pages. The only lawful basis for an environmental impact statement of this length is a determination that the proposed action is of extraordinary complexity. Volume I contains no such determination. The phrases "extraordinary complexity," "page limit," and "Fiscal Responsibility Act" do not appear anywhere in the document, and 42 U.S.C. 4336a is cited nowhere in it. The Draft EIS asserts compliance with "other relevant laws and regulations" while exceeding the one quantitative constraint those laws place on the document itself, and without invoking the exception that would authorize the excess. This is not a matter of formatting. The page limit operates together with 7 CFR 1b.7(i), which directs that issues not of a substantive nature receive the briefest possible discussion. A ceiling of 150 pages applied to a rescission affecting approximately 44.7 million acres of National Forest System lands compels the agency to compress its effects analysis, and the extent of that compression depends directly on which ceiling the responsible official was working to. A document written to 150 pages must omit substantially more analysis than one written to 300. The public reading this Draft EIS cannot tell which constraint shaped it, because the document never says - and the difference is roughly 90 pages of effects analysis across 44.7 million acres. I request that the responsible official make and document the extraordinary-complexity determination required by 42 U.S.C. 4336a and 7 CFR 1b.7(a) as the predicate for a Final EIS exceeding 150 pages, or, if no such determination is made, that the Final EIS text comply with the 150-page limit. Under 7 CFR 1b.7(f)(3), the response to this comment should cite where in the Final EIS or the supporting proposal record that determination is accounted for. A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this. CommentID: RLC-20261006-9WBQV3

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The DEIS further reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA

I writing to urge you to choose Alternative 1: Status Quo/No Action in your final ruling on the proposed Roadless Rule Rescission. There are many compelling reasons to oppose the rescission. I’ll list just a few of them, focusing on ones that are particularly pertinent in Montana, which is where I live. I’m sure that you’re hearing about most of these from other folks, so I don’t think there’s a great deal of need for me to go on and on. The public is opposed—overwhelmingly so—to removing protections for roadless areas. More than 99% of responses received thus far are against the rescission of the Roadless Rule. Even amongst folks who can’t be bothered with writing letters, support for Roadless Areas has been around 76%. These are public lands we’re talking about, and how the public would like to see them used ought to weigh heavily in the decision-making process. Municipal Watersheds will be degraded. Building more roads in our National Forests will increase erosion, which will add to run-off and water purification costs. More than a third of Montanan’s water comes directly from or is downstream of roadless areas. Wildlife habitat will be further fragmented. I’m lucky enough to make my home in the Greater Yellowstone Ecosystem (outside Livingston, MT), which is “the most intact temperate ecosystem in the world,” according to wildlife biologist Doug Smith. Removing the roadless buffer along the edges of this ecosystem will harm wildlife habitat if/when extractive industries move in. The Greater Yellowstone area draws visitors from around the world and has been studied and written about by many. We need more protections—not fewer—for an ecosystem as important as this one. Recreation Economy. Tourism is a big deal Montana, supporting 1 in 11 jobs. Outdoor recreation is also important to Montana residents, making up 4.9 percent of Montana’s GDP. 5.9 of Montanans work in fields related to outdoors recreation. Much of this recreation takes place on public lands that are easily accessible from cities and towns, and these places often include IRAs. It seems unlikely that the extractive industries enabled by rescinding roadless protections will provide a net gain for Montana’s economy, since tourism and outdoor recreation would likely suffer. Maintenance Backlog for Existing Forests Service Roads. If we can’t take care of the ones we already have, we probably don’t need more. Enough said. Private Inholding Access. This is a big one, especially for those of us who live near or like to recreate in the Crazy Mountains. The Crazy Mountains are made up of “checkerboard” public and private land ownership, though some sections (not the right ones, in my opinion) were consolidated a couple of years ago. Most of the checkerboard is currently within the Crazy Mountain IRA. If roadless protections are removed, it will be easier for owners of private inholdings to petition for permission to build a road to their property. These roads would fragment wildlife habit, disrupt public recreation, and have a negative impact on tribal resources. The boon this would provide for owners of formerly difficult-to-access private inholdings is substantial, and casts new light on the checkerboard consolidation deal brokered by the Yellowstone Club in 2025. Wildfire Reduction. This is one of the primary reasons given by the Forest Service for its need to rescind the Roadless Rule. However, scientific evidence does not support the building of roads as a way of reducing wildfire risk—in fact, human caused ignitions in Montana are more than 8 times higher within 100 yards of a road than they are on more remote forest service land. I live a couple of miles from an IRA that runs along the northern edge of Absarokas, and the wildfires we’d had in this area since I’ve lived here tended to be fought by air. Some ignitions occurred on private property (often, a vehicle was involved), others were caused by lightning strikes, but the outcome was the same: the sky was abuzz. At times, firefighters were dropped into wilderness areas to fight fire on the ground—but roads provided little in the way of meaningful firefighting access. Plus, there’s enough wiggle room in the current Roadless Rule to allow for forest thinning and controlled burns in the WUI. Though it will never be perfect, I believe that the Roadless Rule and wildfire protection for our towns and neighborhoods in the urban interface can successfully coexist. Thanks for hearing me out. There’s plenty more I could say, but I believe I’ve gone on for long enough. I hope you make a decision that serves the general public, not a select few. Please go with Alternative 1. The other options serve neither our forests nor the people who love them.

I oppose the proposal to fully and partially rescind the Roadless Area Conservation Rule. As someone who lives in the Tongass National Forest rescinding the Roadless Rule will greatly negatively impact thousands and that’s just here in Alaska! Rescinding the Roadless Rule will not meaningfully reduce wildfire risk. In fact, it's likely to increase it. - "The proportion of human-caused fires in Roadless areas is less than half. on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads." (pg 86; see Aplet et al. 2026) USFS doesn't have the budget to maintain their existing road infrastructure, much less new ones. - Costs for maintaining roads = $5,000-$50,000 / mile. Costs for building new roads = $80,000 - $2 million / mile, depending on if the road is dirt, gravel, or asphault. (pg 42) - The Forest Service has a $7 billion deferred maintenance backlog, and an estimated $1.6 billion is needed annually to maintain existing roadways. In 2023, the USFS received <20% of this amount for road maintenance. (pg 42) - Less than 30% of NFS roads are in 'good condition' (pg 40) - The DEIS states "...revenue generated by timber sales or other resource extraction activities would be used for some road-related system management but not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." (pg 45) These are just a couple examples of the many why rescinding the Roadless Rule is shortsighted and reckless. The decisions of what happens to our public lands are most often made by those who will never be impacted by their actions and the communities who rely on our public lands. Destroying our forests and public lands for short term gains will be irreversible. Please stop this madness. Concerned Juneau and Tongass National Forest resident.

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. My name is Dawson Autry and I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The humpback whales we watched around Baranof Island brought me to this fight. I want those waters protected, and I want to know exactly how logging the Port Alexander and North Baranof roadless areas, covering 120,681 acres and 314,089 acres respectively in the Tongass National Forest, will affect the humpback whales who frequent those waters. The Tongass is the largest intact temperate rainforest left on Earth, holding over 12,930 miles of salmon-producing streams. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. I oppose that outcome completely. I also paddle parts of the Teanaway River, which flows through the Teanaway roadless area in Wenatchee National Forest. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Washington State is currently in the fourth consecutive year of drought and in a drought emergency. Our rivers have remained free flowing. How will rescission affect the volume of water and sediment load in the Naches, Tieton, and Yakima rivers and all their tributaries on the east side of the Cascades? Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in habitat the DEIS identifies as Essential Fish Habitat and critical habitat managed by NMFS. I want to know what the effect on local salmon runs will be, and I ask the agency to answer that question squarely in the final record. We have visited Hyder, Alaska the last two summers and enjoyed watching the bears fishing at the USFS Fish Creek Wildlife Observation Site. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. How will rescission affect the number of bears and salmon that come to that observation site? The agency must address this. The national forests of Washington state already show scars from previous National Forest roads that remain in place, many of those roads receiving no maintenance. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. What will happen to the service level on current National Forest roads if the roadless rule is repealed and additional roads are built? How much will that cost taxpayers? The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. The agency's own record also states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on wildfire and fuels management grounds. Those two positions cannot both be right. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely, Margaret Van Cleve Selah, WA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We are already seeing what happens when we use too many resources. Let's back off taking from the earth for awhile. Water from national forest country in the Pacific Southwest Region reaches as many as 2,264,400 people downstream, by the agency's own data. My tap may be one of them. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The substance of round one is never answered I commented in the first round, and I have read what the agency says it did with everything we sent. Its own account describes counting, not answering: By the agency's own count, over 220,000 comment letters were received, representing over 625,000 submissions, and approximately 99 percent were generally opposed to the rescission. The DEIS says the comments helped inform the alternatives and identifies no issue that changed anything. Counting comments is not responding to them. I ask that the agency state which substantive issues from the first comment period altered the proposal, and which were rejected and why. Issue 2: Tribal consultation is incomplete and its summary is withheld from comment I commented in the first round and waited to be heard. By the agency's own record, others owed a far more formal hearing are still waiting too: The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analysed; the final impact statement arrives only when comment is closed. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule. Issue 3: Every conservation alternative was eliminated by how the purpose was written I took the time to comment before, and I expected the alternatives to reflect what the public asked for. The agency's own document shows how it wrote every protective option out of consideration: Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. Issue 4: Reliance interests are invited and never assessed How this reaches me is stated above in my own words, and that is a reliance interest. The agency asked for exactly this and then weighed none of it: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Brenna Geehan San Francisco, CA

To Whom it May Concern: I live in Seattle, WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, living in or near a National Forest community, and Trail runner. Natural places, untouched by roads and development, are critical for the health of our environment and for our own enjoyment and appreciation of the world. Lake Ann Trail is one place that has shaped my views on this proposal. It is within the Mount Baker North Inventoried Roadless Area in Mount Baker-Snoqualmie National Forest. We hiked to Lake Ann this past weekend, and were blown away by the natural scenery! The trail meanders through a basin surrounded by rocky peaks and golden meadows. The lake itself was a gorgeous jade, surrounded by golden larches just reaching their peak. These places need to be preserved for future generations! I am concerned about wildlife habitat and landscape connectivity. Large areas without road access provide more protection for the habits of diverse species of plants and wildlife. I am concerned about clean water and healthy watersheds. Roads disrupt natural vegetation and waterways that protect our water sources. They also create pollution, which risks the health of our watersheds and the plants and wildlife sustained by them. Roadless areas matter to me for recreation and the experiences they provide. Being able to visit these incredibly special places is a privilege, and one that we are uniquely honored to have in our country. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Roads are associated with increased fire risk through the increased opportunity for wildfire ignition. The data shows that a majority of human caused wildfires ignite near areas with road access. I am concerned about increased timber-development pressure in currently roadless areas. The importance of a healthy tree canopy cannot be overstated, particularly at a time when we are facing increasing stresses on the climate. I believe maintaining a national conservation baseline matters. The US is special BECAUSE of the vast areas of undeveloped nature. Unlike Europe and other more densely populated countries we have the opportunity to preserve these spaces and should not be short-sight about this. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rescission of the Roadless Area Conservation Rule is, as far as I can tell, purely about removing regulatory burden. It does not promise road development. It does not promise logging. It simply strips away protection from some of the last remaining old growth forestland in the world, for no reason the agency has made plain. This is old growth. It takes centuries to even approach that designation. Reforestation efforts across the world today pale in comparison to what true old growth forest represents. If roads go in and that land is destroyed, nothing like it may never be able to grace the earth again. The Forest Service held more than 600 public meetings and took 1.6 million public comments to put this rule in place. To undo something so substantial without a single comparable public process is, to me, a mistake. I ask that the agency explain what process it believes substitutes for that record of public participation, and why rescission of a rule built on 1.6 million comments requires none of its own. On water, the agency's own data shows that 24 million Americans drink water that originates in these roadless areas. Roads are known to cause contamination in the areas where they are built. The agency's own analysis confirms this directly, finding that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Rescinding this rule opens those watersheds to exactly that kind of harm, affecting the drinking water of millions of Americans with little to no real benefit. I ask the agency to explain on the record what specific, quantified benefit justifies that risk to public water supplies. On wildfire, the proposal invokes forest health and fuels management as justification for rescission. The agency's own record says the opposite: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal offers no reconciliation with that finding. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On the state-by-state approach, the agency has already traveled this road and lost. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Courts rejected that state-by-state substitute before. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried to replace the national rule with state petitions. On statutory authority, the proposal argues the 2001 rule exceeded what Congress authorized. A federal appellate court already answered that question: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain on the record the basis for any position to the contrary. Finally, on administrative burden, the rule as written already contains exceptions, including for "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific burdens those exceptions fail to address. It must do so, with quantification, before rescission can stand as a proportionate response to any genuine operational difficulty. Future generations deserve to have this land, to experience the beauty the world has to offer, and we are discussing potentially opening the door to take that away.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet found in backcountry areas is not available anywhere near roads and human development. I have hiked and camped in many such places, and I know that feeling of time slowing down, that grounded, peaceful quality that simply does not exist where roads are found. Each backcountry location is incredibly unique in so many ways, and each one we have matters for that variety, for the ecosystems found there, and for ourselves and our children's children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes a poor case for doing so. Start with fire. The agency's own findings state that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nevertheless justifies rescission partly on wildfire and fuels management grounds. The agency needs to explain, in plain terms, why this proposal departs from its own prior findings on fire occurrence, and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold up either. The record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those are small numbers to set against significant permanent losses. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. Meanwhile, the road system the agency would expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot demonstrate a net positive outcome justify enlarging that liability? The agency has also been down this road before. The record quotes the agency itself expressing dissatisfaction with the Roadless Rule and rejecting its "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That dissatisfaction led to a state-by-state replacement, and the Ninth Circuit struck it down. The proposal moves in the same direction again. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and it must explain how this proposal avoids the specific legal deficiencies identified the last time it tried to substitute state processes for one national rule. Finally, the existing rule already accommodates a range of management needs. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The exceptions for public health and safety, existing mineral leases, and community wildfire protection are already in the text. The agency claims administrative burden justifies rescission, but it has not shown which specific burdens those exceptions fail to address. It should identify them, by category, and quantify them before going further. The places I am writing about are irreplaceable. That variety of ecosystems, that quiet, that slow-down feeling, once a road cuts through it, it does not come back. The agency has not made a factual, legal, or economic case sufficient to justify this rescission, and I urge it to withdraw it. Kristen Portland, Oregon

I strongly oppose the USDA’s proposal to eliminate, weaken, or alter the Roadless Rule. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. As stated in the Draft Environmental Impact Report (DEIS), the Rationale for the Proposed Rule is to reinstate “….important management tools for key areas where there are needs or opportunities to address overgrown and fuel-loaded national forests.” Essentially, repealing the 2001 Roadless Rule will allow the construction of roads to facilitate management of overgrown and fuel-loaded national forests. However, the Department’s own analysis indicates that it will have the opposite effect. Page 85 of the DEIS states that “Past research and new analyses presented here indicate that more fires, both in absolute numbers and density, originate on other NFS lands compared to IRAs and wilderness areas. The DEIS goes on to state that “The proportion of human-caused fires in IRAs and wilderness is less than half that on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads.” Furthermore, the DEIS states that “the new analysis presented in this DEIS indicates that other NFS lands also have about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates. The number of “actionable” and reportable wildfires may also be generally greater in areas outside of roadless or wilderness areas.” The DEIS fails to analyze the economic benefits and reduced negative impacts of focusing management actions on “other NFS lands” compared to IRAs and wilderness area. As stated on page 26 of the DEIS, “Alternatives analyzed in detail must be technically and economically feasible and meet the purpose and need (NEPA section 102 (2 (c)(iii)), 7 CFR 1b.7(h)). Analyzing increased management of “other NFS lands” is technically and economically feasible and meets the purpose and need of “reducing regulatory burden” and providing “management flexibility”. For these reasons, I believe the Department has failed to comply with NEPA, and the 2001 Roadless Rule should remain in place until an additional alternative (increased management of other NFS lands) is fully analyzed. Sincerely, Jeff Stephens OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing lakes, rivers, creeks, and streams without roads cutting through the surrounding land is one of the few remaining privileges available to people willing to make the trek. That is not a small thing. The ecosystems and habitats that support the life in those waters only hold together because human intrusion has been limited. To continuously push the development of infrastructure where it is not needed will lead to the devastation of it all entirely. I hike and camp for the same reason: to experience wildlife as it is, to disconnect, to encounter nature without extreme human intrusion. A large majority of this country has already been developed for commercial, agricultural, and residential use. What remains unroaded and intact should stay that way. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule in full and ask the agency to answer the specific questions raised below. The agency justifies this proposal in part on wildfire and fuels management grounds, but its own record contradicts that justification. The agency found that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Opening more roadless acres to road construction under that finding is not a fire management strategy. I ask the agency to explain how the proposal departs from those prior findings and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as weak. The agency's own analysis shows that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The agency cannot establish a net benefit from this action, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The agency must explain, in plain terms, how that arithmetic supports rescission. The agency also argues that state-specific approaches can replace a single national rule. But the agency's own record acknowledges that it "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The last time the agency substituted local decision-making for the national rule, the Ninth Circuit found that approach legally deficient. The agency has not explained how this proposal avoids the same deficiencies, and it has not addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. A clear answer to both points is required. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. That question has already been litigated. A federal appellate court reviewed the challenge to the rule and held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency needs to state plainly what basis it has for a contrary position, given that a federal court has already ruled on this question. This land was meant to remain untouched and preserved. Preserving the national forests for their ecosystems and wildlife is just as important as any commercial use. The agency should answer each of these points in the final record before any action on this proposal is taken. Sincerely, Mary Landaberde Groveland, Florida

Dear Joshua White, I am a person of faith who cares about protecting the Pacific Northwest fishery, clean water and old-growth and legacy forests. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. Increased road building may increase human incursion into areas prone to wildfire. Mining will pollute pristine waters that support the Alaskan fishery. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. I would like the Forest Service to protect watershed integrity and intact ecosystems in the vast and beautiful northern forest. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Kathleen D Delbecq

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas of western Montana are the foundation of the outdoor life I value. Hiking, rafting, camping, hunting, fishing, and skiing in these places matters to me, and so does the wildlife that depends on them, including the birds that rely on intact, unroaded habitat to survive. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask this agency to answer, in writing, the questions its own analysis leaves open. Start with fire. The agency justifies this rescission partly on wildfire and fuels management grounds, yet its own draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That sentence is in the agency's own record. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to explain, in plain terms, why this proposal departs from its own prior findings, and to reconcile the rescission with the ignition data in that table. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres. These are not abstract figures. These acres produce habitat for the birds and wildlife I described, and they sit inside watersheds that serve 1,287 municipal water intakes across the Northern region. The birds I look for in these places depend on the continuity of that habitat. The agency's own DEIS cites the finding that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The DEIS also cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears. No projection applies it to the 40.1 million acres of potentially affected environment. I ask that the agency close that gap: apply the cited fragmentation range to the full affected acreage and show what it means for bird communities and other wildlife in Montana and beyond. The same omission appears when it comes to hunting. The DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." Trails near Wilderness and Wilderness Study Areas in western Montana are places where these dynamics are real, not theoretical. Yet nowhere in the document does the agency project what road-building and increased access would do to elk populations or hunter opportunity at any scale. The agency should provide that projection. Carbon storage is raised and then set aside. The DEIS cites the estimate that "these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The document then concludes that these lands will continue to sequester and store carbon, with no analysis of what harvest and roading under any alternative would actually change. Roughly 0.9 billion metric tons is not a number that can be mentioned and ignored. The agency must quantify the projected change in carbon storage and sequestration under each alternative before this rulemaking moves forward. Protection of these places is critical. The intact ecosystems of western Montana, the trails adjacent to Wilderness and Wilderness Study Areas, the birds and wildlife that use them, all of this is at stake. The agency's own data on fire ignition, fragmentation, elk behavior and carbon storage each point in the same direction, and none of it is reconciled with the decision to rescind the rule. I ask that the agency treat these gaps as the serious analytical failures they are and address each of them fully in any final record of decision. Sincerely, Carla Belski Whitefish, MT

I oppose the proposal to rescind the Roadless Rule. I co-own a small photography business that photographs proposals and elopements in the backcountry. Our clients don't book us to stand beside a logging road. They come for quiet, intact wild places, and that landscape is the foundation of our livelihood. For 25 years, the Roadless Rule has given businesses like mine something rare: predictability. We can plan seasons, invest in this work, and promise couples these places will still be here. Rescinding the rule trades that lasting value for short-term flexibility. The economics don't add up. Visitors to roadless areas spent $8.5 billion in nearby communities in 2024 (DEIS p. 212), while timber from these areas is projected to generate just $2.2 to $11.4 million a year (p. 220). The DEIS itself notes that outfitters and guides may face higher costs (p. 224). Small businesses like mine would pay for a harvest that earns far less than the recreation it displaces. The wildfire rationale is thin. Per the DEIS, human-caused fires are a much smaller share of fires in roadless areas than elsewhere on national forest land, and ignition density is about four times higher on other lands (pp. 86, 89). The document also acknowledges that timber projects are the primary motivation and funding source for new roads (p. 102). That makes this look more like a timber policy than a fire policy. We can't maintain the roads we have. The Forest Service reports a $7 billion maintenance backlog, and fewer than 30% of its roads are in good condition (pp. 40, 42). The DEIS concedes timber revenue wouldn't cover the cost of building and maintaining new roads (p. 45). Water and wildlife are at stake. About 7,000 municipal water intakes sit in watersheds containing roadless areas (p. 120), and landslides are 6 to 9 times more likely near forest roads (p. 111). These lands overlap the range of more than 300 threatened, endangered, and proposed species (p. 160). Tribal interests deserve more than a promise. The DEIS acknowledges possible reduced access to treaty-reserved resources and sacred sites (pp. 201-202). Please keep the rule in place, and give the public a comment period equal to a decision affecting tens of millions of acres. These untouched areas are also where I spend my own time: skiing, hiking, mountain biking, paddleboarding, river rafting, wildlife viewing, stargazing, and foraging. It's incredibly important to me and to anyone else who recreates in these areas that they remain wild wilderness.

•I oppose the Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. •The Forest Service should strengthen the Roadless Rule, not eliminate it. The current rule provides essential protections but still permits damaging activities in Inventoried Roadless Areas. •Rescission would remove national protections from approximately 45 million acres of National Forest lands, exposing intact wildlife habitat and watersheds to additional logging, grazing-related roads, mining, and fragmentation. •Research examining 1,500 fires shows that protected (unroaded) forests burn at lower intensity and have lower rates of fire spread when controlled for weather conditions. Roads can increase human-caused fire ignitions and spread invasive plants. •The Forest Service should close loopholes that permit logging and the construction of so-called “temporary roads” in roadless areas. Temporary roads can cause lasting harm to wildlife habitat, soils, and watersheds. •The 2001 Roadless Rule does not address livestock-grazing impacts, and grazing has continued uninterrupted in Inventoried Roadless Areas. A mapping analysis estimates that between 10 million and 15 million acres of these lands are actively grazed by domestic livestock each year. Livestock can damage streams and springs, remove riparian vegetation, compact soils, spread invasive plants, and displace native wildlife. New road construction would enable harmful livestock grazing to expand. •The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values. •The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies. •The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use. Here are some helpful talking a points you can use. Keep the first and last and just focus one a few points from the middle. and TELL them about your self and why you care.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless areas are very important to me. I could speak to generally how they help create more diverse and wild landscapes everywhere not just in their vicinity. The United States actually still has wild places unlike many other countries. But I will speak to my specific experience within Deep Creek Roadless Area. I hike there for the last 10 years every year. I love how I can not hear vehicles. I would be heartbroken if this place did not exist or if it was destroyed. To even build a single road in this area I am sure would destroy a lot. The waters in the creek are so clean and the hot springs so delicately placed near the creek. All that would be polluted with run off if roads were built. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Deep Creek (23,869 acres), San Bernardino National Forest, California. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I photograph trees, and my work is part of the recreation economy this document weighs. The agency certifies no impact while the analysis beside it says otherwise: The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Foreseeable plan amendments are placed beyond scope I photograph landscapes, and every frame depends on what the management plans allow next. The agency concedes where this leads and then declares it out of scope: The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. Issue 3: Reliance interests are invited and never assessed I photograph wildlife, and years of that work are built on these protections holding. That is a reliance interest, and the agency invited me to name it: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 4: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Katherine Bauer Corona Del Mar, California

Re: RIN 0596-AD66; Docket FS-2025-0001 — Roadless Area Conservation To the U.S. Dept. of Agriculture and U.S. Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and request that USDA select the No Action Alternative and retain the Rule. If changes are necessary to address wildfire, forest health, or unusual local conditions, USDA should adopt targeted amendments rather than eliminate the nationwide conservation framework. USDA argues that rescission would provide greater local flexibility. Local conditions certainly matter, but local decision-making and national minimum protections are not mutually exclusive. The Roadless Rule establishes a conservation baseline while already allowing exceptions. USDA should identify specific situations in which those exceptions are inadequate and address those problems directly. Road construction and fiscal responsibility-USDA's analysis states that approximately 18.2 million acres of affected inventoried roadless areas are covered by existing plans that could allow permanent road construction following rescission. At the same time, the Forest Service has a $6.9 billion deferred-maintenance backlog for existing roads and bridges. Before making millions of additional acres potentially available for roads, USDA should fully consider the long-term costs of constructing, maintaining, repairing, monitoring, and eventually decommissioning them. Forest Service research also documents hydrological, ecological, aquatic-habitat, wildlife, biodiversity, and other effects associated with forest roads. Wildfire-I recognize the need to reduce wildfire risk and protect communities. However, USDA has not demonstrated that complete rescission is necessary to accomplish these objectives. The proposal itself acknowledges that increased public access can increase human-caused wildfire ignition. Where a community, watershed, or infrastructure faces a demonstrated wildfire threat that cannot reasonably be addressed under the existing Rule, USDA should create a narrowly tailored exception. Roads genuinely necessary for community protection or ecological restoration should be distinguished from roads facilitating commercial timber harvest, mining, energy development, or other resource extraction. Forest plans are not an equivalent replacement-Individual forest plans do not provide the same consistent national protection as the Roadless Rule. USDA acknowledges that plans may later be amended, potentially allowing additional roads and timber harvest. Rescission therefore replaces a national conservation standard with protections that can vary by forest and change over time. It also shifts the burden to citizens, Tribes, communities, and other interested parties to repeatedly participate in forest-plan amendments and individual project decisions to protect areas currently covered by a national rule. Roadless lands have multiple values-Roadless areas should not be evaluated primarily according to resources that might be extracted from them. They provide watersheds, wildlife habitat, biodiversity, hunting and fishing, recreation, scenic landscapes, cultural resources, carbon storage, scientific value, and opportunities for quiet and remote recreation. Once roads fragment an intact landscape, restoring its previous roadless character can be difficult, expensive, or impossible. The potential permanent loss of these values deserves substantial weight. Tribal concerns-USDA reports that the majority sentiment among Tribal governments consulted was opposition to rescission. Concerns included sacred sites, gathering areas, water quality, subsistence resources, cultural survival, ancestral homelands, and the burden of repeatedly participating in project-level reviews. These concerns demonstrate a significant problem with replacing national protection with project-by-project decision-making. USDA should give substantial weight to Tribal consultation before making such a consequential change. A better alternative-I urge USDA to retain the 2001 Roadless Rule while addressing demonstrated management problems through targeted amendments. Any new exception should require a showing that road construction is necessary and that a less environmentally damaging alternative is not reasonably available. USDA should also fully account for lifecycle road costs and preserve national protections for watersheds, wildlife, biodiversity, cultural resources, Tribal interests, and remote recreation. A national conservation standard and responsible local forest management can coexist. Where the Rule creates a demonstrated obstacle to necessary management, USDA should address that specific problem rather than rescind nationwide protections covering millions of acres. For these reasons, I respectfully request that USDA withdraw the proposed rescission of 36 CFR Part 294, Subpart B and retain the 2001 Roadless Area Conservation Rule. Thank you for considering my comments.